1 151 FERC 61,049 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION 18 CFR Part 284 [Docket No. RM ; Order No. 809] Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities (Issued April 16, 2015) AGENCY: Federal Energy Regulatory Commission. ACTION: Final rule. SUMMARY: In this Final Rule, the Federal Energy Regulatory Commission (Commission) is revising its regulations to better coordinate the scheduling of wholesale natural gas and electricity markets in light of increased reliance on natural gas for electric generation, as well as to provide additional scheduling flexibility to all shippers on interstate natural gas pipelines. The revised regulations in this Final Rule modify the scheduling practices used by interstate pipelines to schedule natural gas transportation service and provide additional contracting flexibility to firm natural gas transportation customers through the use of multi-party transportation contracts. The revisions in this Final Rule, together with the Commission s action in certain related proceedings, will better ensure the reliable and efficient operation of both the interstate natural gas pipeline and electricity systems. DATE: This rule will become effective [Insert_Date 75 days after publication in the FEDERAL REGISTER]. The incorporation by reference of certain publications listed
2 Docket No. RM in this rule is approved by the Director of the Federal Register as of [insert date 75 days after publication in the Federal Register]. FOR FURTHER INFORMATION CONTACT: Anna Fernandez (Legal Information) Federal Energy Regulatory Commission Office of the General Counsel 888 First Street, NE Washington, DC (202) Caroline Daly Wozniak (Technical Information) Federal Energy Regulatory Commission Office of Energy Policy and Innovation 888 First Street, NE Washington, DC (202) SUPPLEMENTARY INFORMATION:
3 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities Docket No. RM ORDER NO. 809 TABLE OF CONTENTS Paragraph Numbers I. Background A. Notice of Proposed Rulemaking B. NAESB C. Subsequent Developments II. Discussion III. Gas Day A. NOPR Proposal B. NOPR Comments C. Data Request and ISO and RTO Responses D. Comments on Data Request E. Commission Determination IV. Natural Gas Transportation Nomination Timeline A. Background B. Natural Gas Transportation Day-Ahead Cycles NOPR Proposal Revised NAESB Day-Ahead Nomination Cycles NOPR Comments Commission Determination C. Intraday Nomination Cycles NOPR Proposal NAESB s Revised Intraday Nomination Cycles Comments Commission Determination V. DSPS Proposal
4 Docket No. RM ii A. Background B. DSPS s Proposed National Changes Comments Commission Determination C. 1-Year Pilot Program Comments Commission Determination VI. Multi-Party Transportation Contracts A. Background B. NOPR Proposal C. Comments D. Commission Determination VII. Notice of Use of Voluntary Consensus Standards VIII. Incorporation By Reference IX. Information Collection Statement X. Environmental Analysis XI. Regulatory Flexibility Act Certification XII. Implementation Schedule A. Comments B. Commission Determination XIII. Document Availability XIV. Effective Date and Congressional Notification
5 151 FERC 61,049 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION Before Commissioners: Norman C. Bay, Chairman; Philip D. Moeller, Cheryl A. LaFleur, Tony Clark, and Colette D. Honorable. Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities Docket No. RM ORDER NO. 809 FINAL RULE (Issued April 16, 2015) 1. In this Final Rule, the Federal Energy Regulatory Commission (Commission) revises Part 284 of the Commission s regulations relating to the scheduling of transportation service on interstate natural gas pipelines to better coordinate the scheduling practices of the wholesale natural gas and electric industries, as well as to provide additional scheduling flexibility to all shippers on interstate natural gas pipelines. The Final Rule changes the nationwide Timely Nomination Cycle nomination deadline for scheduling natural gas transportation from 11:30 a.m. Central Clock Time (CCT) to 1:00 p.m. CCT and revises the intraday nomination timeline, to include adding an additional intraday scheduling opportunity during the gas operating day (Gas Day). The Final Rule effectuates these changes by incorporating by reference into the Commission s regulations the standards developed and filed by the North American Energy Standards
6 Docket No. RM Board (NAESB). 1 The revised regulations in this Final Rule also provide additional contracting flexibility to firm natural gas transportation customers through the use of multi-party transportation contracts. 2. On March 20, 2014, the Commission instituted proceedings under section 206 of the Federal Power Act (FPA) 2 to ensure that each Independent System Operator s (ISO) and Regional Transmission Organization s (RTO) scheduling, particularly its day-ahead scheduling practices, correlate with any revisions to the natural gas scheduling practices ultimately adopted by the Commission in this Final Rule. The Section 206 Order provides that ninety days after publication of this Final Rule in the Federal Register each ISO and RTO is required to propose tariff revisions to coordinate its day-ahead market with the changes adopted herein or to show cause why its existing scheduling practices need not be changed. This Final Rule together with actions already undertaken by the Commission in other dockets as discussed below, additional regional efforts underway by market participants and stakeholders, and any actions taken in the section 206 proceeding on ISO and RTO scheduling practices is designed to better ensure the reliable and efficient operation of both the interstate natural gas pipeline and electricity systems. 1 NAESB is accredited by the American National Standards Institute (ANSI) as an accredited standards organization. NAESB complies with ANSI s requirements that its procedures are open to materially affected entities and that the standards represent a reasonable consensus of the industry without domination by any single interest or interest category. 2 California Independent System Operator Corp., et al, order initiating investigation into ISO/RTO scheduling practices and establishing paper hearing procedures, 146 FERC 61,202 (2014) (Section 206 Order).
7 Docket No. RM However, for the reasons described below, the Commission declines to adopt the proposal to change the start of the Gas Day. It is not clear that requiring a change in the Gas Day start time would provide sufficient benefits to outweigh the operational and safety impacts and costs of making such a change. While the Commission declines to take action in this proceeding to change the start of the Gas Day on a nation-wide basis, we note that since the issuance of the NOPR in March 2014 both ISO-NE and PJM (the two regions that appear to be of the most concern) have recently undertaken operational and market actions to address the availability and performance of generators, including gas-fired generators, in their footprints. These and other regional efforts to address generator performance may result in natural gas-fired generators and other market participants in these regions taking actions to alleviate some of the electric industry fuel supply concerns underlying the Gas Day proposal in the NOPR. I. Background 4. The Commission s existing regulations incorporate by reference the interstate natural gas pipeline scheduling business practice standards of NAESB s Wholesale Gas Quadrant (WGQ). 3 NAESB is a consensus standards organization composed of representatives of all segments of the natural gas industry and the electric power industry. Since 1996, these standards have established nationwide timelines that the industry and the Commission have determined are necessary to establish a more efficient and integrated pipeline grid. 3 See 18 CFR (a) and (b) (2014).
8 Docket No. RM The existing 24-hour operating day, or Gas Day, for interstate natural gas pipelines begins at 9:00 a.m. CCT and ends at 9:00 a.m. CCT the following day. All nominations for interstate natural gas pipeline transportation service are for a daily quantity to be transported over the 24-hour Gas Day. 4 The rate at which a shipper may use its contracted quantity on a given interstate pipeline, also known as a flow rate, is determined by the individual pipeline s tariff and the flexibility of that pipeline to permit shippers to use gas on other than a uniform hourly basis over the 24-hour Gas Day (i.e., non-ratable flows). Except for special services, pipeline services are generally based on the assumption of uniform hourly flows over the Gas Day The current NAESB WGQ standards establish four standard nomination periods (i.e., periods during which a shipper can request transportation service under its contract) for a Gas Day. As summarized in Table 1 below, shippers have two nomination opportunities prior to the day of gas flow, the Timely Nomination Cycle and the Evening Nomination Cycle, and two opportunities to revise their nominations on the day of gas 4 The NAESB WGQ standards refer to CCT which refers to the actual time in the Central Time Zone, reflecting Central Standard Time or Daylight Savings Time, whichever is applicable. 5 During much of the year, most interstate natural gas pipelines can accommodate significant variations in hourly flow rates. However, during high demand periods when pipeline capabilities are being fully utilized to provide firm transportation services, a pipeline may announce a critical notice period, where shippers are expected to stay in balance. Some pipelines also offer enhanced services that permit subscribing shippers more variable hourly flow rates.
9 Docket No. RM flow (Intraday 1 and Intraday 2). Individual pipelines may offer additional scheduling opportunities beyond the standard nomination cycles. 6 Table 1: Current NAESB Gas Nomination Cycles Nomination Nomination Notification of Nomination Effective Bumping Cycle Deadline (CCT) Schedule (CCT) (CCT) of IT Timely 11:30 a.m. 4:30 p.m. 9:00 a.m. Next Day N/A Evening 6:00 p.m. 10:00 p.m. 9:00 a.m. Next Day Yes Intraday 1 10:00 a.m. 2:00 p.m. 5:00 p.m. Current Day Yes Intraday 2 5:00 p.m. 9:00 p.m. 9:00 p.m. Current Day No 7. With respect to electric industry scheduling practices, the Commission has accepted regional variation in the development of scheduling practices in ISO and RTO electric markets, each of which has established its own scheduling timelines. For most electric utilities, the 24-hour operating day begins at 12:00 a.m. local time. The ISOs and RTOs practice of scheduling resources generally includes the commitment and dispatch of sufficient, deliverable generation to supply load in a reliable least cost manner, all based on generator availability and the transmission facilities that will be in service that day. To perform the unit commitment and dispatch processes used to develop daily resource schedules, each ISO and RTO has its own timeline for collecting supply offers from generators and expected demand from load serving entities on the day 6 See, e.g., Texas Gas Transmission LLC, 137 FERC 61,093 (2011), order on compliance, 138 FERC 61,176 (2013) (Texas Gas); and Gulf South Pipeline Company LP, 141 FERC 61,262 (2012) (Gulf South).
10 Docket No. RM prior to the operating day. The ISOs and RTOs then run market algorithms that determine the least cost set of resources that can be used to serve the next day s load. Each ISO and RTO also performs a reliability unit commitment process to procure resources, in addition to those resources committed to serve the load bid into the dayahead market, as necessary to meet the ISO s or RTO s own forecast of the next day s load or other system needs. Each ISO and RTO establishes its own timing for executing the day-ahead and reliability scheduling processes, including the times of day when bids and offers are due to the system operator, when the market and reliability processes are run, and when the results of the scheduling processes are made available to generators In non-iso and RTO systems, the Commission s pro forma OATT specifies that firm interchange schedules need to be submitted by 10:00 a.m. day-ahead or a reasonable time that is generally accepted in the region and is consistently adhered to by the Transmission Provider Recent developments in the wholesale natural gas and electricity industries particularly the organized electricity markets signal that changes to the gas nomination 7 FERC, Operator-Initiated Commitments in RTO and ISO Markets, Docket No. AD (Dec. 2014), available at 8 Pro forma OATT section Schedules for Non-Firm Point-To-Point Transmission Service must be submitted to the Transmission Provider no later than 2:00 p.m. of the day prior to commencement of such service. Pro forma OATT section 14.6.
11 Docket No. RM schedule may be needed. 9 Reliance on natural gas as a fuel for electric generation has steadily increased in recent years. 10 This trend is expected to continue, resulting in greater interdependence between the natural gas and electric industries. 11 Several events over the last few years, such as the Southwest Cold Weather Event 12 and the extreme and sustained cold weather events in the eastern U.S. in January 2014, 13 show the crucial 9 The Commission is directing ISOs and RTOs to make corresponding changes in the Section 206 Order. 10 See, e.g., U.S. Energy Information Administration, Annual Energy Outlook 2014 with projections to 2040 at ES-4 (April 2014); North American Electric Reliability Corporation, 2014 Long-Term Reliability Assessment (November 2014) at See, e.g., U.S. Energy Information Administration, Annual Energy Outlook 2014 with projections to 2040 (April 2014) (Natural gas-fired generation is projected to overtake coal-fired generation for U.S. electricity generation by Natural gas share of U.S. electricity generation is projected to increase from 30 percent in 2012 to 35 percent in 2040.); ICF Assessment of New England s Natural Gas Pipeline Capacity to Satisfy Short and Near-Term Electric Generation Needs: Phase II Final Report (November 20, 2014); North American Electric Reliability Corporation, 2014 Long-Term Reliability Assessment (November 2014) at See FERC/NERC, Report on Outages and Curtailments During the Southwest Cold Weather Event of February 1-5, 2011 (2011), available at 13 The widespread and record low temperatures during January 2014 resulted in coincident record peak demand for natural gas throughout the Midwest, Northeast, Mid- Atlantic, and Southeast regions leading to constrained pipeline capacity and high natural gas prices. In addition, in February 2014, arctic temperatures limited the availability of natural gas to supply New Mexico and Southern California leading CAISO to issue a system alert and a request for consumers to reduce power demand around the system. CAISO invoked increasingly stringent measures throughout the day to move generation off natural gas, reduce demand, and maintain sufficient supply to meet firm load. See FERC Staff Presentation Recent Weather Impacts on the Bulk Power System January 16, 2014,
12 Docket No. RM interrelationship between natural gas pipelines and electric transmission operators and underscore the need for improvements in the coordination of wholesale natural gas and electric markets. 10. Since early 2012, the Commission has conducted multiple technical conferences and requested comment on various aspects of gas-electric interdependence and coordination in order to better understand the interface between the electric and natural gas pipeline industries and identify areas for improved coordination. 14 In a report issued on November 15, 2012, Commission staff noted that natural gas and electric industry participants highlighted the need for greater alignment of natural gas and electric scheduling practices. 15 At the direction of the Commission, staff conducted an additional technical conference in April 2013 to specifically discuss natural gas and electric scheduling practices, including whether and how natural gas and electric industry scheduling practices could be harmonized in order to achieve more efficient scheduling practices for both industries See Coordination Between Natural Gas and Electricity Markets, Docket No. AD (Feb. 15, 2012), available at 15 Staff Report on Gas-Electric Coordination Technical Conferences, Docket No. AD (Nov. 15, 2012) (November Staff Report), available at 16 Coordination between Natural Gas and Electricity Markets, Docket No. AD (Mar. 5, 2013) (Notice of Technical Conference), available at
13 Docket No. RM At the April 2013 conference, participants identified several areas in which the differences between the nationwide natural gas schedule and the regional electric schedules can affect the provision of reliable service and may create inefficiencies in scheduling that result in less cost effective use of resources. The participants identified three major issues. These included: (1) the difference between the standardized operating day of interstate natural gas pipelines and the operating days of electric utilities (including ISOs and RTOs); (2) the lack of coordination between the day-ahead process for nominating interstate natural gas pipeline transportation services and the day-ahead process for scheduling electric generators, particularly those in the ISOs and RTOs; and (3) the lack of intraday nomination opportunities on interstate natural gas pipelines, which limits the ability of gas-fired electric generators, as well as other shippers, to revise their nominations during the operating day. Several conference participants stressed that, due to the difficult policy questions involved, they would need Commission policy guidance before they would be able move forward on coordination of the natural gas and electric industries existing scheduling practices. A. Notice of Proposed Rulemaking 12. Based on the increased reliance on natural gas as a fuel for electric generation and in consideration of the discussions at the technical conferences and filed comments, the Commission concluded that the concerns identified by the industries warranted further action. On March 20, 2014, the Commission issued the Notice of Proposed Rulemaking (NOPR or Proposed Rule) to address concerns with divergent interstate natural gas pipeline and wholesale electric utility scheduling practices, as well
14 Docket No. RM as concerns regarding the flexible and efficient use of pipeline capacity by natural gasfired generators and other shippers The NOPR proposed three changes to the nationwide natural gas scheduling practices: (1) move the start of the Gas Day from 9:00 a.m. CCT to 4:00 a.m. CCT; (2) move the start of the first day-ahead gas nomination opportunity for pipeline scheduling (Timely Nomination Cycle) from the current 11:30 a.m. CCT to 1:00 p.m. CCT 18 ; and (3) modify the current intraday nomination timeline to provide four intraday nomination cycles, instead of the existing two, to provide greater flexibility to all pipeline shippers. 14. The NOPR also proposed to require interstate natural gas pipelines to offer multiparty transportation contracts to provide multiple shippers the flexibility to share interstate pipeline capacity to serve complementary needs in an efficient manner, and the NOPR provided clarification of the Commission s no-bump policy with respect to any enhanced nomination opportunity proposed by a pipeline (beyond the standard nomination opportunities). 15. Recognizing that the natural gas and electricity industries were best positioned to work out the details of how changes in scheduling practices could most efficiently be 17 Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, 79 FR (Apr. 1, 2014), FERC Stats. & Regs 32,700 (2014) (cross-referenced at 146 FERC 61,201 (2014)) (NOPR). 18 The Commission did not propose any changes to the Evening Nomination Cycle.
15 Docket No. RM made and implemented, the Commission provided the natural gas and electric industries, through NAESB, with a period of 180 days after publication of the NOPR in the Federal Register to reach consensus on any revisions to the Commission s proposals regarding the Gas Day and pipeline nomination timeline and either file consensus standards with the Commission or notify the Commission of the natural gas and electric industries inability to reach consensus on any revisions to the Commission s proposals. Comments on NAESB s consensus standards, as well as comments on the Commission s proposals, were to be filed 240 days after publication of the NOPR in the Federal Register, or November 28, In the NOPR, the Commission stated that if the Commission were to adopt regulations that have not been approved by NAESB, it would expect NAESB to integrate the Commission s regulations into its standards within 90 days of the effective date of the final rule and to notify the Commission when the standards have been approved. 16. On the same day the NOPR was issued, the Commission issued two other orders, which, in conjunction with the NOPR, were designed to better ensure the reliable and efficient operation of both the interstate natural gas pipeline and electricity systems. In one order, the Commission instituted proceedings under section 206 of the Federal Power Act FPA 19 to ensure that each ISO s and RTO s scheduling practices, particularly its dayahead scheduling practices, correlate with any revisions to the natural gas scheduling U.S.C. 824e (2012).
16 Docket No. RM practices ultimately adopted by the Commission in the instant proceeding. 20 In the Section 206 Order, the Commission required each ISO and RTO within ninety days of the publication of a Final Rule in this proceeding to: (1) make a filing that proposes tariff changes to adjust the time at which the results of its day-ahead energy market and reliability unit commitment process (or equivalent) are posted to a time that is sufficiently in advance of the Timely and Evening Nomination Cycles, respectively, to allow gasfired generators to procure natural gas supply and pipeline transportation capacity to serve their obligations; or (2) show cause why such changes are not necessary. In the second order, the Commission instituted proceedings, under section 5 of the Natural Gas Act (NGA) 21 to examine whether interstate natural gas pipelines are providing notice of offers to purchase released pipeline capacity in accordance with section 284.8(d) of the Commission s regulations. 22 B. NAESB 17. Following issuance of the NOPR, NAESB reconvened the Gas Electric Harmonization (GEH) Forum as the platform for the gas and electric industries to consider the NOPR proposals, as well as to develop any consensus-based alternatives to 20 Section 206 Order, 146 FERC 61, U.S.C. 717d. 22 Posting of Offers to Purchase Capacity, 146 FERC 61,203 (2014). See also 18 CFR 284.8(d) (2013).
17 Docket No. RM the NOPR proposals. 23 The GEH Forum was tasked with developing a recommendation for consideration by the NAESB Board of Directors (Board). The GEH Forum and NAESB Board convened several meetings between April and June 2014 with nearly five hundred active participants and over seven-hundred participants monitoring the activity, representing all facets of the wholesale gas and wholesale electric markets Four alternatives to the NOPR proposal were considered during the final GEH Forum meeting. 25 The day-ahead and intraday nomination cycles in each package were the same, 26 but the start of the Gas Day in each package was different. Disagreement over the start of the Gas Day prevented the GEH Forum from reaching consensus on any of the alternative proposals to the NOPR. 27 The GEH Forum was also unable to reach consensus on an alternative proposal that did not define the Gas Day, but contained the same day-ahead and intraday nomination schedule as the four alternative proposals. 23 The NAESB Board of Directors formally defined consensus of the GEH Forum as 67 percent affirmative vote of each of the wholesale gas and wholesale electric quadrants and 40 percent affirmative vote of each of the segments of the two quadrants. 24 NAESB June 18, 2014 Report at Id. at Id. at 8. The nomination deadline for the Timely and Evening Nomination Cycles were the same as those proposed in the NOPR 1:00 p.m. CCT and 6:00 p.m. CCT, respectively. The modified NAESB standards proposed only three intraday nomination opportunities, instead of four as proposed in the NOPR. The nomination deadlines for Intraday 1, Intraday 2 and Intraday 3 would be at 10:00 a.m. (bump), 2:30 p.m. (bump), and 7:00 p.m. (no-bump), all CCT. 27 Id. at 9-10.
18 Docket No. RM Several participants expressed concern that any alternative proposal would be incomplete without a Gas Day start time, and indicated that they could not support a package that did not include the start of the Gas Day Despite the inability of the GEH Forum to reach consensus, the NAESB Board directed the WGQ to proceed with the development of standards related to the day-ahead and intraday nomination cycles given the broad agreement among industry participants on those issues. 29 Electric utilities could participate in the WGQ meetings, but only members of the WGQ were eligible to participate in the final vote (i.e., Wholesale Electric Quadrant (WEQ) members that are not also members of the WGQ, such as the ISO and RTO segment, were ineligible to vote on the standards). 20. On June 18, 2014, NAESB filed a status report with the Commission. On September 29, 2014, NAESB filed a second report to supplement the June 18 report and to inform the Commission of the modifications to the NAESB WGQ Business Practice Standards that were developed at the direction of the NAESB Board. 30 The modified 28 Id. 29 Id. at NAESB reports that, in total, there are modifications to twenty-three NAESB WGQ Business Practice Standards: the NAESB WGQ Nomination Related Standard Nos , 1.2.4, 1.3.1, 1.3.2, 1.3.3, 1.3.4, , , , , , and , the NAESB WGQ Flowing Gas Related Standard Nos , 2.3.5, and , the NAESB WGQ Quadrant Electronic Delivery Mechanism Related Standard No , and the NAESB WGQ Capacity Release Related Standard Nos , , , , , , and NAESB states that, pursuant to the direction given by the NAESB Board of Directors, the NAESB WGQ Business Practice Standards are silent as to a start time of the Gas Day. Accordingly, references to the specific start (continued )
19 Docket No. RM NAESB WGQ Business Practice Standards revise the nomination timeline to provide for three intraday nomination cycles in addition to the Timely and Evening Nomination Cycles. NAESB stated that nomination cycles are not dependent upon a specific start time to the Gas Day and are implementable with whichever time the Commission chooses as a start of the Gas Day. On November 26, 2014, NAESB filled another report to inform the Commission of the options the organization may pursue to respond to Commission action within the ninety-day deadline provided in the NOPR, if the Commission adopts regulations not approved by NAESB. C. Subsequent Developments 21. On October 15, 2014, the Commission issued a notice of NAESB s September 29 report. The notice provided that comments in response to the NOPR should address the alternate proposal submitted to NAESB by the Desert Southwest Pipeline Stakeholders during the formal comment period on the proposed modifications to the NAESB WGQ standards. 31 Comments on the NOPR were due on November 28, Seventy-five comments were filed. Comments were received from all sectors of both industries, time of the Gas Day in NAESB WGQ Standard No have been removed and replaced by the placeholder: [?]. Likewise, NAESB WGQ Standard No was revised to contain a generic reference to the start time of the Gas Day. NAESB states that, should the Commission identify a specific start time of the Gas Day, it will revise the language of the NAESB WGQ Business Practice Standards as necessary. NAESB WGQ Annual Plan Item 11c which modified the NAESB standards was approved by the NAESB WGQ Executive Committee and ratified by the NAESB membership on September 22, In addition, Minor Correction M14018 was applied to these standards effective October 10, NAESB Sept. 29, 2014 Report at Appendix C.
20 Docket No. RM including ISOs and RTOs, electric utilities, interstate natural gas pipelines, local distribution companies (LDC), producers, state regulators, electric generators, and other interested persons. 22. On December 12, 2014, Commission staff requested data from each of the six jurisdictional ISOs and RTOs regarding their experience with the impact on reliable and efficient operations of natural gas-fired generators running out of their daily nomination of natural gas transportation service during the morning electric ramp, to the extent this occurs. California Independent System Operator Corporation (CAISO), ISO New England Inc. (ISO-NE), Midcontinent Independent System Operator, Inc. (MISO), New York Independent System Operator, Inc. (NYISO), PJM Interconnection, L.L.C. (PJM), and Southwest Power Pool, Inc. (SPP) each filed a response to the data request. On February 2, 2015, American Public Gas Association (APGA), Natural Gas Council, New England LDCs, 32 and the Enhanced Reliability Coalition 33 filed comments on the ISO and RTO responses. 32 New England LDCs include the following: Bay State Gas Company d/b/a/ Columbia Gas of Massachusetts, The Berkshire Gas Company, Connecticut Natural Gas Corporation, Fitchburg Gas and Electric Light Company, City of Holyoke, Massachusetts Gas and Electric Department, City of Norwich, Department of Public Utilities, Liberty Utilities (EnergyNorth Natural Gas) Corp. d/b/a Liberty Utilities, Middleborough Gas & Electric Department, New England Natural Gas Company d/b/a Liberty Utilities, Northern Utilities, Inc., NSTAR Gas Company, The Southern Connecticut Gas Company, Westfield Gas & Electric Department and Yankee Gas Services Company. 33 The Enhanced Reliability Coalition represents the views of a wide variety of electric and gas industry companies located throughout the United States and Canada that provide services such as natural gas production, interstate and intrastate gas pipeline transportation, natural gas distribution, natural gas procurement for core and industrial (continued )